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External study

Preface to the CRIDS report (2011) on data protection at INTERPOL

By Billy Hawkes, Chairman of the Commission6 November 2012

This Report was commissioned by the Commission for the Control of INTERPOL’s Files (CCF) from the University of Namur’s Information Society Centre (CRIDS). The Centre was asked to do an assessment of data protection within INTERPOL in a comparative international context.

The Report is structured in two main parts:

The First Part examines INTERPOL’s rules on the processing of personal data. The Report notes the challenge to INTERPOL represented by the widely different standards of data protection that operate in the 190 Member States.

The Second Part examines the systems of oversight of these rules, with particular focus on the role of the CCF. The Report describes INTERPOL as having a “system of multi-level accountability” – “accountability” being understood as responsibility and willingness to demonstrate such responsibility to relevant stakeholders. The main accountability levels are: National Central Bureaus and authorized entities, INTERPOL General Secretariat and the CCF.

There is a brief concluding section on INTERPOL’s system of data protection, described as one of multi-level accountability; on the challenges of the introduction of the I-link information system; and on the increasing challenges to the immunity of international organizations.

The Report makes a number of specific recommendations. Some of these recommendations – including those on downloading, security and accountability – have already been taken into consideration in the new ﻿INTERPOL Rules on the Processing of Data (RPD) which entered into force on 1 July 2012.

The Appendix to this preface gives information on:

The list of recommendations which have already been taken into consideration in the new rules on the processing of data;

The elements introduced in the new rules which did not exist when the study took place;

Clarifications on some issues.

Many user-guides and other tools have also been developed by the General Secretariat to facilitate the implementation of the new Rules and to take account of the new functionalities offered by I-link.

The Commission for its part has taken account of the recommendations addressed to it. For example, it makes every effort to get approval from National Central Bureaus to communicate to those seeking its assistance the information about them that is contained in INTERPOL’s databases.

The Report, as well as contributing to the new Rules, is also a useful reference document on how INTERPOL’s system of data protection compares with those in operation in other international organizations and on the particular constraints that inevitably apply in an organization dedicated to cooperation between police forces.